eIDAS 2 and the e-CMR: the trust layer under digital freight documents

The e-CMR is the electronic version of the consignment note for international road transport, based on the Additional Geneva Protocol of 20 February 2008 to the CMR Convention. EU law recognises it by name: since Regulation (EU) 2020/1055 amended the cabotage rules, evidence at a roadside check may be presented or transmitted electronically in a revisable structured format, with the e-CMR cited as the example (Article 8(4a) of Regulation (EC) 1072/2009). The hard part of digitising freight paperwork is not the document itself but the trust behind it: an inspecting officer or trading partner in another Member State needs to establish that the signer is who they claim to be, was authorised to sign, and that the content has not been altered since. That is the role of the eIDAS framework — Regulation (EU) 910/2014, substantially amended by Regulation (EU) 2024/1183 (eIDAS 2), in force since 20 May 2024. The consignment note carries the transport content; eIDAS carries the proof of who signed and what that signature is worth.

Article 25 of Regulation (EU) 910/2014 sets three rules that matter for freight documentation. An electronic signature may not be denied legal effect or admissibility as evidence solely because it is electronic. A qualified electronic signature (QES) has the equivalent legal effect of a handwritten signature. And a QES based on a qualified certificate issued in one Member State is recognised as qualified in all others — the property that counts when a consignment note signed in one country is checked in another. Below the qualified level sits the advanced electronic signature (Article 26): uniquely linked to the signatory, capable of identifying them, created under their sole control, and tamper-evident. If your e-CMR platform works at the advanced rather than the qualified level, its signatures are not void — but only the qualified level carries automatic handwritten equivalence and EU-wide recognition. For companies there is the electronic seal: a qualified seal enjoys a presumption of integrity and correctness of origin of the sealed data (Article 35), relevant where a platform or carrier seals consignment-note data as a legal person rather than signing as an individual.

Regulation (EU) 2024/1183 obliges every Member State to provide at least one EU Digital Identity Wallet, for natural and legal persons alike, within 24 months of the entry into force of the implementing acts (Article 5a) — on the European Commission's timeline, by the end of 2026. The wallet is defined to store and present identity data and electronic attestations of attributes, and to sign with qualified electronic signatures; wallets must offer natural persons QES free of charge by default, though Member States may limit free use to non-professional purposes — so an operator should not assume free wallet signatures for day-to-day commercial signing. Attestations are the second building block: an attribute is defined as a characteristic, quality, right or permission of a natural or legal person or of an object, and a qualified electronic attestation has the same legal effect as a lawfully issued paper attestation (Article 45b) — the intended digital carrier for licences, mandates and certificates. Finally, Article 5f(2) creates an acceptance duty: private relying parties that must use strong user authentication for online identification under law or contract — the regulation names transport among the areas — have to accept the wallet no later than 36 months after those same implementing acts, roughly a year after the wallets themselves are due. Micro and small enterprises are exempt, and acceptance operates on the user's voluntary request.

Separate from identity law, Regulation (EU) 2020/1056 (eFTI) obliges competent authorities to accept regulatory freight transport information electronically when operators provide it through a certified eFTI platform, in machine-readable format with a human-readable view on request (Articles 4 and 5). The acceptance obligation starts 30 months after the first delegated and implementing acts entered into force; according to the Commission the regulation applies in full from 9 July 2027. Its scope covers information requirements in, among others, the cabotage evidence rules of Regulation (EC) 1072/2009, combined transport under Directive 92/106/EEC, and dangerous-goods transport documentation (ADR/RID/ADN chapter 5.4 via Directive 2008/68/EC). Two boundaries matter. eFTI binds authorities, not operators: the regulation is explicitly without prejudice to the option of presenting information on paper. And it governs the business-to-authority layer, while the consignment note as a contract between consignor, carrier and consignee remains governed by the CMR regime. In practice the tracks converge: the same e-CMR data can serve as the contract document between parties and as regulatory evidence toward authorities — provided the identity and signature layer underneath is verifiable.

If you operate as a carrier, forwarder or shipper in cross-border road transport, three planning questions follow. Signature level: establish whether your e-CMR or transport-management platform uses advanced or qualified signatures and seals, and what your counterparties and inspecting authorities expect — the qualified level is the one with guaranteed EU-wide effect. Wallet readiness: once wallets are available (due end 2026), drivers and authorised signatories should be able to identify themselves and sign at qualified level from a Member State-provided or recognised wallet, and if your booking or onboarding portals require strong user authentication you probably fall under the acceptance duty of Article 5f(2) — unless you qualify as a micro or small enterprise. Data plumbing: from 9 July 2027 authorities must accept eFTI-platform data, so the certification roadmap of your document vendor becomes a compliance question rather than an IT preference. None of this forces you off paper; but verification of identity, mandates and permits is being standardised at EU level, and onboarding and inspection processes are likely to shift from exchanging documents to verifying credentials.

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